Facts:

The case at hand revolves around the Republic of the Philippines, represented by the Department of Public Works and Highways - National Capital Region (DPWH-NCR) as the petitioner, and the Heirs of Isabel D. Lacsina, represented by Higino Honorato D. Lacsina and Reynaldo D. Lacsina, along with Cabever Realty Corporation and St. Ignatius of Loyola School as respondents. This petition for review on certiorari was filed under Rule 45 of the Rules of Court, assailing the Decision dated October 18, 2018, and the Resolution dated March 21, 2019, of the Court of Appeals (CA) in CA-G.R. CV No. 106325.

The spurious events began on May 12, 2009, when the Republic filed a complaint for the expropriation of three parcels of land located in Ususan, Taguig City, for infrastructure development aimed at alleviating traffic congestion associated with the Taguig Diversion Road. The properties in question were owned by the Heirs of Isabel D. Lacsina (788 sq. m.), Cabever Realty Corporation (1,355

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Facts:

Filing and Nature of the Expropriation Case

• On May 12, 2009, the Republic of the Philippines, represented by the Department of Public Works and Highways – National Capital Region (DPWH-NCR), initiated a Complaint for the expropriation of three properties:
• Lot 5301-A, owned by the Heirs of Isabel D. Lacsina (788 sq. m., originally classified as agricultural, with a provisional zonal valuation of Php2,000.00 per sq. m.).
• Lot 5897-E, owned by Cabever Realty Corporation (1,355 sq. m., classified as commercial, with a provisional zonal valuation of Php6,000.00 per sq. m.).
• Lot 5897-B, owned by St. Ignatius of Loyola School (SILS) (1,654 sq. m., classified as residential, with a provisional zonal valuation of Php5,000.00 per sq. m.).
• The expropriation was sought for the completion of the Taguig Diversion Road to decongest traffic adjacent to General Luna and Bagong Calzada, thereby augmenting the road network in Taguig City.
• The Republic asserted its right to expropriate the properties and, with no contest from the respondents as to the power of eminent domain, the Regional Trial Court (RTC) issued the Order of Expropriation on June 1, 2011.

Respondents’ Objections and Valuation Controversies

• The respondents, which included the Heirs of Isabel D. Lacsina, Cabever Realty Corporation, and St. Ignatius of Loyola School, objected to the provisional valuation of their properties.
• The Heirs of Isabel D. Lacsina argued that the market value of their property should be no less than Php6,000.00 per sq. m. and contended that the Republic had possessed the property without proper compensation.
• In a separate answer, Ma. Evelyn R. Lacsina, widow of Reynaldo Bonifacio D. Lacsina, maintained that the Bureau of Internal Revenue’s (BIR) zonal valuation of their property was Php6,000.00 per sq. m. (as opposed to Php2,000.00 per sq. m.).
• An answer-in-intervention was subsequently filed by Marina M. Rimas and her children (Rei Mari, Rei Francis, and Marie Claire Lacsina), who sought to protect their claim on the share of the late Reynaldo.
• Cabever Realty Corporation contended that, notwithstanding the BIR zonal valuation of Php6,000.00 per sq. m., its property commanded a higher fair market value (Php19,000.00 to Php20,000.00 per sq. m.) due to its commercial location.
• Cabever also sought consequential damages for the unaffected remaining lots, arguing that the resurvey rendered its property into irregular, unusable shapes.
• St. Ignatius of Loyola School (SILS) submitted that its property was not located in the originally designated area but along Gen. Luna Street in Brgy. Tuktukan, Taguig City, and asserted a higher zonal valuation (Php10,000.00 per sq. m.), further seeking a just compensation range of Php25,000.00 to Php30,000.00 per sq. m. along with consequential damages.

Commission of Just Compensation

• The parties mutually agreed to establish a board of commissioners pursuant to Rule 67 of the Rules of Court to determine just compensation.
• The board, through its July 10, 2012 Report, recommended:
• The fair market value be set at Php10,000.00 per square meter for the expropriated properties.
• Payment of compensation for consequential damages for the unaffected lots of Cabever Realty Corporation and St. Ignatius of Loyola School at Php5,000.00 per square meter.

Proceedings at the Regional Trial Court (RTC)

• The RTC rendered its Decision on February 18, 2015.
• Despite the board’s recommendation, the RTC fixed just compensation at the higher rate of Php15,000.00 per sq. m., taking into account the commercial use of the properties.
• The RTC awarded specific monetary sums to each respondent based on their respective property areas.
• The RTC, however, did not award any consequential damages for the unaffected portions of Cabever and SILS, reasoning that the consequential benefits outweighed the damages.
• The Republic’s subsequent Motion for Reconsideration was denied in a September 4, 2015 Order.

Proceedings at the Court of Appeals (CA)

• The Republic appealed, challenging the RTC’s determination of just compensation.
• In its Decision dated October 18, 2018, the CA:
• Modified the RTC’s award by reducing just compensation to Php10,000.00 per sq. m. for the expropriated properties.
• Awarded consequential damages at Php5,000.00 per sq. m. for the unaffected portions of Cabever’s and SILS’s properties.
• Determined that interest on the award should accrue from the filing of the Complaint (May 12, 2009), initially at 12% per annum until June 30, 2013, and thereafter at 6% per annum.
• The Republic then filed a Motion for Partial Reconsideration to remove the consequential damages award, which the CA denied on March 21, 2019.

Petition Before the Supreme Court

• The Republic filed a Petition for Review on Certiorari under Rule 45, arguing on two grounds:
• That the CA exceeded its jurisdiction by deciding on consequential damages—a matter not raised on appeal by respondents Cabever Realty Corporation and SILS.
• That even if within its purview, respondents Cabever and SILS were not entitled to receive consequential damages for the unaffected portions of their properties.
• The respondents submitted their respective Comments in response.

Issue:

Whether the Court of Appeals erred in awarding consequential damages in favor of Cabever Realty Corporation and St. Ignatius of Loyola School even though these parties did not specifically appeal the RTC’s denial of such damages.

• The issue centers on the finality of the RTC decision where no affirmative relief for consequential damages was sought by the respondents.

Assuming the CA had jurisdiction to review the matter, whether Cabever Realty Corporation and St. Ignatius of Loyola School are entitled to payment of consequential damages for the unaffected portions of their respective properties.

• This involves examining whether the evidence supports the award of such damages.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)